Nippon Cargo Airlines Co., Ltd. Narita International Airport — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave, S.E. Washington, D.C. 20590 FEB 1 6 2010 Mr. Iwahiko Uehara Manager, Quality Control Corporate, Traffic Department Nippon Cargo Airlines Co., Ltd. Narita International Airport Narita-shi, Chiba 282-0004, Japan Ref. No.: 09-0254 Dear Mr. Uehara: This responds to your E-mail dated October 28, 2009 requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the loading of hazardous materials in aircraft. Specifically, you ask ifthere are specific quantity limits for packages of hazardous materials bearing a "Cargo Aircraft Only" label when loaded in the same Class C cargo compartment with packages of hazardous materials that are eligible for carriage on passenger-carrying aircraft. The answer is yes. For each package containing a hazardous material acceptable for carriage aboard passenger-carrying aircraft, no more than 25 kg (55 pounds) net weight ofhazardous material may be loaded in an inaccessible manner. In addition to the 25 kg limitation above, an additional 75 kg (165 pounds) net weight ofDivision 2.2 (non-flammable compressed gas) may be loaded in the same compartment. See § 175.75(c). "Loaded in an inaccessible manner" means cargo loaded in a manner that precludes a crew member or other authorized person from handling, and when size and weight permit, separating such packages from other cargo during flight. You state that the Class C compartment of your aircraft is inaccessible to crew members. Thus, you are limited to 25 kg of hazardous material that is acceptable for carriage aboard passenger-carrying aircraft, and in addition 75 kg of division 2.2 (nonflammable compressed gas) in the same Class C compartment. Packages containing hazardous materials that are marked "Cargo Aircraft Only" are considered to be "accessible" for the purposes of § 175.75 when loaded in a cargo#

Page 2compartment certified by FAA as a Class C cargo compartment as defined in 14 CFR 25.857(c). See § 175.75(f). Thus, there is "no limit" to the quantity ofcargo aircraft only packages that may be loaded in a Class C cargo compartment. I hope this answers your inquiry. Sincerely, atk(o~ Charles E. Betts Chief, Standards Development Ice of Hazardous Materials Standards#

Page 3Drakeford, Carolyn (PHMSA) From: Sent: To: Cc: Subject: Importance: Attachments: Betts, Charles (PHMSA) Tuesday, November 03,20098:16 AM Drakeford, Carolyn (PHMSA) Gorsky, Susan (PHMSA) FW: USG-13 High USG-13 . E, c1nen IG.AA..1a ~llS·/) A,'r oct ~ {)2 5,-/ USG-13 Summary 280CT09 Update.... Original Message ----From: Iwahiko Uehara [iwahiko.uehara@nca.aero] Sent: 10/28/2009 04:18 PM ZE9 To: Janet McLaughlin; "Kevin.leary@dot.gov" <Kevin.leary@dot.gov> Cc: Kazuhide Takahashi <kazuhide.takahashi@nca.aero>; Yosuke Hara <yosuke.hara@nca.aero> Subject: USG-13 Dear Ms McLaughlin and Mr.Leary, It was a very nice to see you in Montreal at ICAO DGP/22. We discussed for new 49CFR provisions and clarified as Dangerous Goods bearing CAO label, can be loaded into Class C Cargo Compartment without accessibility as attached. In the attached sheet, my clarifications are highlighted in red. And I understood that the provisions for Dnagerous Goods permitted on passenger aircraft (not bearing CAO label), are still unchanged and those are permitted with a limitation of 75kg for Division 2.2 materials and 25kg for other Dangerous Goods except Class 3 PG III without a subsidiary risk, Class 6, Class 7 and Class 9 in an inaccessible caogo compartment including Class C Cargo Compartment. I would apprciate if you could your guidance for more details. If CAO DGs are loaded in Class C Cargo Compartment (Lower Deck of our Aircraft) with inaccessible condition, in addiition to the amount of those CAO DGs, can other DGs permitted on PAX aircraft be loaded to same Cargo Compartment with limitation of 25kg & 75kg ? Sorry for bothering you. But I would really appreciate if you could give your answer. Best regards I.Uehara/Nippon Cargo Airlines. Iwahiko Uehara ..tJj .~ Manager, Quality Control Corporate Nippon Cargo Airlines e-mail iwahiko.uehara@nca.aero TEL +81-476-32-9652 FAX +81-476-32-9173 1#

Page 4Is Handling Guideline for flights to/from USA U<-OK Dangerous Goods (Packages not bearing CAO label) Class t: \,;argo \';ompartment {accesslllle} (Main Deck) inaccessible accessible Freight Container llpressed gas 75kg(165Ibs) per compartment No limit 75kgs per Freight Container bsidiary-risk No limit No limit No limit ( risk of Flammable No limit No limit No limit ( risk No limit No limit No limit No limit No limit No limit ; 2Skg(55Ibs) per compar'LIllent No limit 25kgs per Freight Container ,0 Dangerous Goods (Packages bearing CAO Label) Class E Cargo Compartment (accessible) (Main Deckl inaccessible accessible Freight Container npressed gas Forbidden No limit Forbidden bsidiary-risk No limit No limit No limit , risk of Flammable No limit No limit No limit , risk No limit No limit No limit No limit No limit No limit i Forbidden Nollm!t Forbidden Class C Cargo Compartment (FWD :of lower Deck) inaccessible 7Skgs per compartment No limit No limit No limit No limit 25kgs per compartment Class C Cargo Compartment (FWD ComDartment of lower Deck) inaccessible No limit No limit No limit No limit No limit Nollml! UPDATED on 280CT09 Class C Cargo Compartment IlAFT t of lower Deck) Inaccessible 75kgs per compartment No limit No limit No limit No limit 25kgs per compartment Class C Cargo Compartment I(AFT ComDartment of lower Deck) inaccessible No limit • • No limit No limit No limit No limit No limit#